references to distributions shall not apply; and

subject to section 116(5), no deduction or addition shall be made for charges on income, or for capital allowances and charges, nor in any accounting period for losses incurred in any other period nor for any expenditure to which section 401(1) applies; and

a change in the persons engaged in carrying on the trade F22profession or business shall be treated as the transfer of the trade F22profession or business to a different company if there continues to be a company so engaged after the change, but not a company that was so engaged before the change.

the reference in subsection (1) to a company resident in the United Kingdom were a reference to a company that is not so resident; and

in subsection (2), after “carried on” there were inserted “in the United Kingdom through a F29permanent establishment”.

a company resident in the United Kingdom (“the resident partner”) is a member of a partnership which resides outside the United Kingdom or which carries on any trade, profession or business the control and management of which is situated outside the United Kingdom, and

by virtue of any arrangements falling within section 788 (“the arrangements”) any of the income or capital gains of the partnership is relieved from corporation tax in the United Kingdom.

in respect of the whole or any part of the value of, or of any portion of, the partner company’s share in the profits or loss of any accounting period of the partnership, another member of the partnership or any person connected with another member of the partnership receives any payment or acquires or enjoys, directly or indirectly, any other benefit in money’s worth; or

in respect of the whole or any part of the cost of, or of any portion of, the partner company’s share in the loss of any accounting period of the partnership, the partner company or any person connected with that company receives any payment or acquires or enjoys, directly or indirectly, any other benefit in money’s worth, other than a payment in respect of group relief to the partner company by a company which is a member of the same group as the partner company for the purposes of group relief.

the company’s share in the loss of the relevant accounting period of the partnership and its share in any charges on income, within the meaning of section 338, paid by the partnership in that accounting period shall not be available for set-off for the purposes of corporation tax except against its share in the profits of the trade carried on by the partnership; and

except in accordance with paragraph (a) above, no trading losses shall be available for set-off for the purposes of corporation tax against the company’s share in the profits of the relevant accounting period of the partnership; and

except in accordance with paragraphs (a) and (b) above, no amount which, apart from this subsection, would be available for relief against profits shall be available for set-off for the purposes of corporation tax against so much of the company’s total profits as consists of its share in the profits of the relevant accounting period of the partnership; and

F31. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

the profits or loss to which the company’s share is attributable were the profits of, or the loss incurred in, a trade carried on by the partnership; and

any allowance to be given effect under Part 2 of the Capital Allowances Act in respect of a special leasing of plant or machinery were an allowance to be given effect in calculating the profits of that trade.

in respect of a loss incurred by a company in a trade, or of charges paid by a company in connection with the carrying on of a trade, in a relevant accounting period; F40. . .

F40. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

the amount which the partner company has contributed to the trade as capital and has not, directly or indirectly, drawn out or received back (other than anything which it is or may be entitled so to draw out or receive back at any time when it carries on the trade as a limited partner or which it is or may be entitled to require another person to reimburse to it), and

the amount of any profits of the trade to which the partner company is entitled but which it has not received in money or money's worth.

all the activities of the partnership are treated as carried on in partnership by its members (and not by the partnership as such),

anything done by, to or in relation to the partnership for the purposes of, or in connection with, any of its activities is treated as done by, to or in relation to the members as partners, and

the property of the partnership is treated as held by the members as partnership property.

References in this subsection to the activities of the limited liability partnership are to anything that it does, whether or not in the course of carrying on a trade, profession or other business with a view to profit.

references to a partnership include a limited liability partnership in relation to which subsection (1) above applies,

references to members of a partnership include members of such a limited liability partnership,

references to a company do not include such a limited liability partnership, and

references to members of a company do not include members of such a limited liability partnership.

if the cessation is only temporary, or

on the appointment of a liquidator or (if earlier) the making of a winding-up order by the court, or

on the occurrence of any event under the law of a country or territory outside the United Kingdom corresponding to an event specified in paragraph (a) above.

the amount subscribed by F55it, and

the amount of F56its liability on a winding up.

F57it has previously, directly or indirectly, drawn out or received back,

F57it so draws out or receives back during the period of five years beginning with the relevant time,

F57it is or may be entitled so to draw out or receive back at any time when F58it is a member of the limited liability partnership, or

F57it is or may be entitled to require another person to reimburse to F58it.

F59it is liable to contribute to the assets of the limited liability partnership in the event of F60the partnership's being wound up, and

F59it remains liable so to contribute for the period of at least five years beginning with the relevant time (or until F61the partnership is wound up, if that happens before the end of that period).

F67the member carries on the trade as a member of the limited liability partnership, and

any of F65the member's total unrelieved loss remains outstanding.

any loss sustained or incurred by the member in the trade in that F69accounting period were increased by an amount equal to so much of F70the member's total unrelieved loss as remains outstanding in that period, or

(if no loss is so sustained or incurred) a loss of that amount were so sustained or incurred.

any relief given under any provision of F73the Corporation Tax Acts (otherwise than as a result of subsection (2)) in respect of F72the member's total unrelieved loss in that or any previous F71accounting period, and

any amount given or allowed in respect of F72the member's total unrelieved loss as a result of subsection (2) in any previous F71accounting period (or which would have been so given or allowed had a claim been made).